2016 (11) TMI 785

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....r the Appellant. Shri Shyamlal Karoliya, AC (AR) for the Respondent. ORDER Per: Raju The appellants, M/s Persistent System Ltd., received certain services from their associate company located overseas. The appellants made the requisite debit/credit entries in their accounts. The appellants paid the Service Tax when the actual payment was made to the service provider. The Revenue allege....

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....se penalty on the appellant by invoking extended period of limitation. 2. Learned Counsel for the appellants argued that this a revenue neutral situation as they were entitled to take the credit of Service Tax paid and therefore they could not have been intention to evade payment of duty. It was argued by the appellant that the said explanation of Rule 6 was included just to clarify that the gr....